2018 opened up opportunities for further use of digital technologies, specifically Remote Patient Monitoring (RPM) and Telehealth. These important updates are intended to encourage the adoption of RPM technologies in clinical practices and work towards continued synergies between mhealth innovators and providers, supported by CMS.

The focus of these updates by CMS to the 2018 Physician Fee Schedule Final Ruling (PFS) is leveraging wearables and smart devices at home, as well as patient generated health data (PGHD) as part of care coordination and management efforts.

These changes began formation in July 2017, when CMS released the Physician Fee Schedule proposed rule for 2018, with the groundwork for additional commenting and discussion around RPM which led to the further incorporation in the final rule released at the end of 2017 and leaves open opportunity for further incorporation as we move into the future.

What are the changes and what can we expect?

The final ruling of the PFS, after solicitation for comments on the Connected Procedural Technology (CPT) code 99091, CMS announced this code will be unbundled. The code respectively covers “collection and interpretation of physiologic data (e.g., ECG, blood pressure, glucose monitoring) digitally stored and/or transmitted by the patient and/or caregiver to the physician or other qualified healthcare professional (QHCP), qualified by education, training, licensure/regulation (when applicable) requiring a minimum of 30 minutes of time” and “analysis of clinical data stored in computers (e.g., ECGs, blood pressures, hematologic data).” This means providers are now able to get reimbursed separately for the time spent on collection and interpretation of health data that is generated by patients remotely.

Additionally, after CMS created a process for adding new telehealth services, as a result of a number of stakeholder proposals they received, CMS also included a number of services for 2018 that will be reimbursed when performed using telehealth activities:

For a long time RPM services haven’t had their own codes, they were always considered under “miscellaneous services” or could be grouped with bundled payment initiatives. RPM technology use could be grouped with other services, but it never had its own codes. The first step in this movement has started with this unbundling. Although this is a positive step in the right direction, we can expect to continue seeing progress and improvements made in the years to come.

The decisions by CMS were applauded by the Connected Health Initiative (CHI) a group of industry stakeholders who had started lobbying CMS in support of these incentives in February of 2017.

In a statement at the end of 2017, CHI Executive Director said in a statement, “These new rules are an important step forward for America’s connected health innovators, doctors, and most importantly patients. Until now, connected health technologies have been effectively locked out of the most important part of America’s healthcare system, Medicare and Medicaid.”

Key Guidelines & Takeaways

In the final PFS for 2018, CMS provided a few guidelines for providers as they begin to use these newly unbundled codes in their clinical practices:

Providers will need to obtain beneficiary consent for the services, in advance and document in the patient’s medical record

For new patients, providers will need to initiate these services in a face-to-face visit (i.e. annual wellness visit)

Per patient, providers can use the code 99091 once in a 30-day period

The codes will not be subject to the restrictions on originating sites, which allows users of the technology further flexibility

Overall, these CMS updates show that they are moving much more rapidly to incentivize clinicians to integrate digital technologies – specifically Remote Patient Monitoring technologies, as we continue to transition to value-based care delivery. As digital health technologists, we’re here to help hospitals, health systems and clinicians meet these regulatory incentives through top of the market RPM platforms to easily enable meeting these new opportunities. We will continue to see more reform and discussion around these digital initiatives supported by CMS as the year progresses.